Industry Evolution: Training is Key in OQ NPRM

One of the most significant expansions in PHMSA's OQ NPRM is the broadening of training requirements. The proposed rule goes well beyond what is currently required, introducing mandatory training in several new areas. Here is EWN's breakdown of what's being proposed.

Mandatory OQ Training

Under proposed 49 CFR 192.805(b)(9), operators would be required to provide training to covered task performers. The current rule focuses primarily on evaluation; the proposed rule adds formal training as a distinct requirement. New defined terms — Knowledge, Skills, and Abilities (KSAs) and an updated definition of "Qualified" — were approved by GPAC and LPAC to support these training requirements.

Mandatory Supplemental Training

Under proposed 49 CFR 192.805(b)(10), PHMSA proposed mandatory supplemental training whenever there are significant changes to covered tasks, procedures, or equipment. After PAC review, the threshold was revised to "significant changes" — providing some operational flexibility while still ensuring workers are updated when material changes occur.

Mandatory Control Room Training

In response to NTSB Recommendation P-12-8, the proposed rule adds new control room training requirements under 49 CFR 192.631 and 195.446. Control room operators would be required to complete specific training addressing the unique hazards and responsibilities of their roles.

Mandatory Evaluator Training

A brand new requirement under proposed 49 CFR 192.805(b)(11) and 195.505(b)(11) would require that the individuals who conduct OQ evaluations must themselves be trained to perform evaluations. This closes a significant gap in the current rule, which does not address evaluator qualifications.

OQ for Gathering Lines

As noted in other installments of this series, the proposed rule also extends OQ requirements to gathering lines under new 49 CFR 192.9 and 195.11 provisions. This will bring gathering line operators into the OQ framework for the first time.

PHMSA estimates significant costs associated with these training expansions. EWN is positioned to help operators meet these requirements efficiently. Contact us to learn more.